Martin v. State
2013 Minn. LEXIS 36
| Minn. | 2013Background
- Martin, age 17 at offense, was convicted of aiding and abetting first-degree premeditated murder and a gang-enhancement for the Lynch killing.
- Direct appeal affirmed; postconviction petition filed in 2011 sought an evidentiary hearing and new trial based on witness recantations and other claims.
- Recantation affidavits by Mack-Lynch and Pettis supported petition; postconviction court denied without an evidentiary hearing under Minn. Stat. § 590.04.
- Postconviction court conflated evidentiary hearing standards with Lamson’s new-trial standard, denying relief.
- Appellate issue focus: (1) entitlement to evidentiary hearing on recantation, (2) ineffective appellate counsel, (3) Knaffla bar on remaining claims.
- Affidavits described as recantations: Mack-Lynch and Pettis claimed prior testimony was false and offered explanations for false testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to an evidentiary hearing on witness recantation | Martin | State | Abused discretion; entitlement to evidentiary hearing remanded for credibility assessment. |
| Ineffective assistance of appellate counsel | Martin | State | No error; appellate counsel's strategy reasonable given weak Rule 20 claim. |
| Knaffla bar on remaining claims | Martin | State | Knaffla bar affirmed for most claims; recantation issue remanded, others barred. |
Key Cases Cited
- Larrison v. United States, 24 F.2d 82 (7th Cir. 1928) (recantation standards; minimal evidentiary-showing for hearing)
- Opsahl v. State, 710 N.W.2d 776 (Minn. 2006) (Lamson test requirements; credibility determinations for recantation)
- Opsahl v. State (Opsahl I), 677 N.W.2d 414 (Minn. 2004) (recantation credibility and need for evidentiary hearing)
- State v. Turnage (Turnage II), 729 N.W.2d 593 (Minn. 2007) (Lamson-like framework for recantation; factors for new trial)
- Vance v. State (Vance II), 752 N.W.2d 513 (Minn. 2008) (minimal indicia of trustworthiness; lack of hearing if affidavits non-credible)
- State v. Vance (Vance I), 714 N.W.2d 428 (Minn. 2006) (recantation context in postconviction)
- State v. Ferguson, 779 N.W.2d 555 (Minn. 2010) (recusal of recantation credibility; preconditions for hearing)
- State v. Ferguson (Ferguson I), 742 N.W.2d 651 (Minn. 2007) (trustworthiness standard for recantation)
- Riley v. State, 819 N.W.2d 162 (Minn. 2012) (standards for evidentiary hearing in postconviction)